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2020 (7) TMI 821 - AT - Income TaxTP Adjustment - working capital adjusted PLI of the comparables not considered - As per assessee PLI of the comparables after carrying out working capital adjustment, which is much less than the PLI the assessee - HELD THAT:- Though the assessee submitted working capital adjusted PLI of the comparables before Transfer Pricing Officer but same was not considered because unadjusted PLI of the assessee was higher than the average marginal comparables and resultantly, no adjustment was proposed to the international transaction of provision of information technology enabled services reported by the assessee As the effect of the working capital adjustment has not been considered or examined by the lower authorities, we feel it appropriate to restore this limited issue whether the adjustment for delayed receivables from associated enterprises get subsumed in working capital adjustment, to the file of the learned Assessing Officer/Transfer Pricing Officer for adjudicating in accordance with law. It is needless to mention that assessee shall be afforded adequate opportunity of being heard. Appeal of the assessee is allowed partly for statistical purposes.
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